MCCLATCHEY v. ASSOCIATED PRESS

Filing 11

Joint MOTION to Extend Time forDiscovery by VALENCIA M. MCCLATCHEY. (Attachments: # 1 Exhibit Notice of Motion# 2 Proposed Order)(Hall, John)

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MCCLATCHEY v. ASSOCIATED PRESS Doc. 11 Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA VALENCIA M. MCCLATCHEY Plaintiff Civil Action No. OS- 145J THE ASSOCIATED PRESS JURY TRIAL DEMANDED Defendant. JOINT MOTION FOR AN EXTENSION OF TIME Plaintiff Valencia McClatchey, and Defendant The Associated Press, by and through their attorneys, hereby submit this Joint Motion for an Extension of Time. In support of the agreed motion , Plaintiff and Defendant state as follows. On July 2S , 2005, this Court entered a Case Management Order and set the following dates: Close of Fact Discovery Expert Reports Responses to Expert Reports December 2 , 2005 December 15, 2005 January 13, 2006 January 31 Expert Depositions 2006 Deadlines for Motions for Summary Judgment February 3, 2006 Plaintiffs pretral narrative statement Defendant's pretrial narrative statement February 21 , 2006 March 14 , 2006 Joint statement re: magistrate judge March 28, 2005 Since the Court's Case Management Order, the parties have Dockets.Justia.com P Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 2 of 3 exchanged documents and written discovery. The parties have been attempting to set deposition dates. However, due to witnesses' schedules , the parties wil be unable to complete faCt discovery by December 2 , 2005. Accordingly, the partes jointly seek a 60-day extension of time and an order setting the following revised schedule: Close of Fact Discovery Expert Reports February 1, 2006 February 15 , 2006 Responses to Expert Reports March 13 2006 Expert Depositions March 31. 2006 Deadlines for Motions for Summary Judgment April 3, 2006 Plaintiffs pretrial narrative statement Defendant's pretrial narrative statement April 21, 2006 May 15, 2006 May 31, 2005 Joint statement re: magistrate judge WHEREFORE , Plaintiffs and Defendant respectfully request that the Court approve the 60-day extension of time and enter the revised schedule above. Respectfully submitted VALENCIA MCCLATCHEY Douglas M. ert Penchi a evine Sullvan Koch & Schulz, LLP 230 Park Avenu . Suite 1160 New York, NY 10169 Phone: 212-850-61 00 Kara L Szpondowski Niro, Scavone, Haller & Niro 181 W. Madison, Suite 4600 Chicago , Ilinois 60602 Phone: 312-236-0733 Fax: 212-850-6299 Fax: 312-23 -3137 ohn E. Hall Eckert Seamans Cherin & Mellott 600 Grant Street ICA/ ittsburgh PA 15219 , 44th Floor 2( 412. 566. 1915 Case 3:05-cv-00145-TFM Document 11 Filed 12/02/2005 Page 3 of 3 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the foregoing MOTION FOR AN EXTENSION OF TIME JOINT was served upon the below listed parties on this 1 day of December, 2005: Gayle C. Sproul Levine Sullivan Koch & Schultz, LLP 2112 Walnut St. , 3 Floor By Mail: Philadelphia, PA 19013 Phone: (215) 988-9778 By Facsimile and Mail: Robert Penchina Levine Sullivan Koch & Schultz, LLP 230 Park Avenue Suite 1160 New York, NY 10169 Phone: (212) 850-6100 Fax: (212) 850-6299 Jo Hall 1;L1e I t9

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